COVID-19 Updates

As the COVID-19 situation evolves, we are keeping a close watch on the trend and will continue to take proactive steps to update our clients on the different economic relief plans available from the various levels of government. Remember, the safety and well-being of our community is paramount so please continue to comply with the government guidelines on social distancing and other measures.

June 15, 2020 Update on CEBA

On June 15, 2020, the CEBA website was updated to include additional FAQ questions. The additions focus on the the details and differences between the applying under the “Non-Deferrable Expenses Steam” as compared to the “Payroll Stream”. In a separate announcement, the Prime Minister stated that applications under the expanded program would commence on Friday June 19, 2020.

In particular:

  • applications under the Payroll Stream (total employment income paid to employees in 2019 greater than $20,000 and less than $1,500,000) will be completed directly through the financial institution in which your business holds its primary business chequing / operating account. The Government of Canada will notify your financial institution and provide funding for your CEBA loan.

  • applications under the Non-Deferrable Expenses Stream (total employment income paid to employees in 2019 of $20,000 or less, and 2020 Eligible Non-Deferrable Expenses – subject to adjustments for support or subsidies under other Government of Canada COVID response programs – greater than $40,000 and less than $1,500,000) will follow a two-step process:

    • Step 1: Businesses will initiate applications directly at their primary financial institution where they hold their primary business chequing / operating account. The financial institution will then direct applicants to Step 2 of the application process.

    • Step 2: Following the initial application through your financial institution, applicants will be directed to a CEBA website to provide supporting documentation of the 2020 Eligible Non-Deferrable Expenses and to complete the application.

      If successful, the Government of Canada will notify your financial institution and provide funding for your CEBA loan.

Additional documents required will include:

  • The name of the financial institution where you submitted your application; and

  • Your 9-digit business number (same number you used in your application with your financial institution); and

  • Electronic or paper copies of Receipts / Invoices / Agreements to be uploaded as evidence of your 2020 Eligible Non-Deferrable Expenses.

The other FAQs added include:

CEBA website

May 25, 2020 Update – CRA Extends Deadlines  

Personal tax deadline follow-up

On Friday (see May 22, 2020 post below) we quoted CRA’s announcement that T1 late-filing penalties will not be charged if returns are filed and payments are made by September 1, 2020.  Some have asked if this was a typo.  It was not.  However, it is important to note that the actual deadline has not been changed to September 1, 2020.  What is the difference between an actual extension of the deadline and CRA simply stating that they will not assess late-filing penalties?  The returns would still be late, however, the primary disincentive (late-filing penalties) would be removed if all conditions are met.

Also, there was a question as to whether self-employed filers (and their spouses) would enjoy a waiver of late filing penalties as well.  CRA updated their website today to confirm that the same relief would be provided: “Penalties (including late-filing penalties) and interest will not be applied if returns are filed and payments are made by September 1, 2020.”  Note, however, that no further extension to GST/HST return deadlines have been announced, so it appears the annual GST return required by many self-employed individuals still needs to be filed by June 30, 2020.  Make sure to check back on the CRA deadline listing page for any changes.

For information on T1135’s and other returns, see “Other information returns, elections, designations and information requests” below.

Corporate tax deadlines

Corporations that would otherwise have a filing deadline in June, July, or August 2020 would have their deadline extended to September 1, 2020.  It appears that the previously extended deadline of June 1 for returns due after March 18 and before June 1 is not being extended.

Trusts deadlines (corrected May 25, 2020, see Note 1)

The June 1, 2020 extended filing date applies to trusts that would otherwise have a filing due date on March 31, or in April or May 2020.

The filing date for the current tax year (including the associated T3 information return) for trusts that would otherwise have a filing due date in June, July, or August 2020 is extended to September 1, 2020.

A September 1, 2020 extended date applies to income tax balances and instalments due on or after March 18 and before September 1, 2020. Penalties and interest will not be applied if returns are filed and payments are made by September 1, 2020.

Other information returns, elections, designations and information requests

Unless otherwise noted, the following applies to other information returns, elections, designations and information requests that are due.

Penalties and interest will not be applied if information returns, elections, designations, and information requests are filed and payments are made by September 1, 2020.

The waiver of penalties and interest for 2019 T1 individual returns and trust returns described above also applies to form T1135 and any elections, forms and schedules that must be filed with the return, provided that they are filed by September 1, 2020.

For 2019 T2 corporate returns, the extension of the filing deadline applies for all purposes. In particular, the extension also applies to form T106, T1135, and any elections, forms and schedules that must be filed with the corporate return.

Important sources and Links

May 19, 2020 Update – CEBA Loan Program Expanded | CECRA more details released 

PM announces updates on the expansion of the CEBA loan program:

  • Canada Emergency Business Account (CEBA) loans program will be expanded for those:

    • who are sole owner-operators;

    • that depend on contractors; and

    • that are family businesses that pay employees by dividends rather than payroll.

  • As well, CEBA will be modified to become available to new businesses (those which have never filed a tax return) and businesses which do not have “business accounts” at the bank, but operate through personal accounts.

  • To qualify under the expanded eligibility criteria, applicants with payroll lower than $20,000 would need:

    • a business operating account at a participating financial institution;

    • a Canada Revenue Agency business number, and to have filed a 2018 or 2019 tax return; and

    • eligible non-deferrable expenses between $40,000 and $1.5 million. Eligible non-deferrable expenses could include costs such as rent, property taxes, utilities, and insurance.

Further details and information in respect of CECRA have been released.

They include:

  • Several sample documents were provided

  • New businesses – Small businesses that opened on or after March 1, 2020 are not eligible.

  • Sub-tenancy – Eligible small business tenants who are in sub-tenancy arrangements are also eligible, if these lease structures meet program criteria.

  • Required 70% decline in pre-COVID-19 revenues

    • Businesses can compare revenues in April, May and June of 2020 to that of the same period in 2019 to measure revenue losses. They can also use an average of their revenues earned in January and February of 2020.

    • If the small business tenant or its ultimate owner produces consolidated statements, then the tenant would use revenues reported for the group level of companies. Alternatively, if the small business tenant does not produce consolidated statements, then it is the specific revenue of the tenant that applies for the $20 million test.

  • Applying later – Property owners can apply later and the program will be applied retroactively.

  • Application end date – The end date for applications is August 31, 2020. Property owners may still apply for assistance once the 3-month period has ended if they can prove eligibility during those months.

  • Excess funds paid by tenants – Property owners must use the funds from CECRA to refund amounts in excess of 25% paid by the small business tenant for the period or at the option of the impacted tenant apply rent paid in excess of 25% to future rent owing by the impacted tenant. ***

  • Rent already corrected – If rent has been collected at the time of approval, a credit to the tenant for a future month’s rent (i.e. July for April) is acceptable — if the tenant chooses this option. This can be a flexible 3-month period.  

  • Tenants can’t pay – Tenants struggling to pay the remaining portion of their rent, may apply for alternate programs.

  • Timing of loan forigveness – This interest free loan will be forgiven on December 31, 2020.

  • What is included in monthly gross rent?

    Monthly gross rent is the total gross rent amount payable by the small business tenant as set out under a valid and enforceable lease agreement. Please see table below for inclusions/exclusions:

    Gross Rent

    1. Net rent / minimum rent / base rent (in a net lease)

    2. Regular monthly installments of operating costs (in a net lease)

    3. Regular monthly installments of property taxes payable to the landlord (in a net lease)

    4. Regular monthly installments of other additional rent amounts payable to the landlord — for example: maintenance costs, repairs, utilities, management fees, etc. (in a net lease)

    5. Gross rent (in a gross lease)

    6. Percentage of sales rent paid (if included in the lease arrangement)

    Excluded from Gross Rent

    1. Damages

    2. Indemnity payments

    3. Payments arising due to tenant default / landlord enforcement

    4. Payments arising due to landlord exercise of self-help remedies

    5. Interest and penalties on unpaid amounts

    6. Fees payable for discrete items or special services (for example: fees to landlord for reviewing plans, supervising work, considering requests for consent, performing exceptional tasks at tenant’s request)

    7. Reconciliation adjustment payments

    8. Amounts required under the lease agreement to be paid separately by the tenant to 3rd parties (for example: property taxes, utilities, insurers)

    9. Costs of non-monetary obligations (e.g., repairs and maintenance)

    10. Insurance proceeds or proceeds from other rent subsidy programs
      Note: applying for insurance coverage does not remove you from being eligible for the program, but it may adjust the amounts received if you successfully receive payments from insurance claims or other programs to cover rent

  • Non-arm’s length tenants – Landlords and tenants who are not at arm’s length will be included in the program as long as there was a valid and enforceable lease agreement in place and the rent under the lease is at market rates.

  • Partial residential use – Commercial properties with a residential component and multi-unit residential mixed-use properties would equally be eligible with respect to their small business tenants.

  • Future rent – The property owner must agree that the rent that is forgiven, reduced and will never be recoverable, collection through significant or disproportionate rent increases. This will also be within the terms of the rent reduction agreement in place between you and your property owner.

April 24, 2020 Update – CEWS Application Guide released

The government has now released the guide for applying for the 75% wage subsidy which opens on Monday, April 27, 2020. Click here for the guide.

April 24, 2020 Update – Commercial rent relief for small businesses

Small businesses with monthly rents of less than $50,000 will be eligible for a 75% reduction for April, May and June. 50% will be covered by the federal government. The remaining 25% will be covered by the lessor. Non-profits and charities will also be eligible.

In particular:

  • The program will provide forgivable loans to qualifying commercial property owners to cover 50 per cent of three monthly rent payments that are payable by eligible small business tenants who are experiencing financial hardship during April, May, and June.

  • The loans will be forgiven if the mortgaged property owner agrees to reduce the eligible small business tenants’ rent by at least 75 per cent for the three corresponding months under a rent forgiveness agreement, which will include a term not to evict the tenant while the agreement is in place. The small business tenant would cover the remainder, up to 25 per cent of the rent.

  • Impacted small business tenants are businesses paying less than $50,000 per month in rent and who have temporarily ceased operations or have experienced at least a 70 per cent drop in pre-COVID-19 revenues. This support will also be available to non-profit and charitable organizations.

More details are to come in Mid May.

April 23, 2020 Update

The FAQ on CERB has been updated.

Some new elements from the update:

Are self-employed small business owners eligible for the Canada Emergency Response Benefit?

Yes, provided they meet the eligibility criteria including that they stopped working due to COVID-19 and do not earn more than $1000 in a period of at least 14 consecutive days in the first benefit period and for the entire four-week benefit period of any subsequent claim.

Small Business owners can receive income from their business in different ways, including as salary, business income or dividends.  In determining their eligibility for the Canada Emergency Response Benefit:

  • Owners who take a salary from their business should consider their pre-tax salary;

  • Owners who rely on business income should consider their net pre-tax income (gross income less expenses);

  • Owners who rely on dividend income should consider this as self-employment income provided it comes from non–eligible dividends (generally, those paid out of corporate income taxed at the small business rate).

Can someone qualify for Canada Emergency Response Benefit if they still have a small amount of income coming into their business account as a sole proprietor to pay some of their business expenses (commercial rent, utility costs, etc.) as long as they are not paying themselves any income from the business?

Yes. To be eligible for the Canada Emergency Response Benefit, you must have stopped working as a result of  reasons related to COVID-19 and receive less than $1,000 in employment or self-employment income for at least 14 consecutive days within the initial four-week period for which you apply. For subsequent periods, you cannot receive more than $1,000 in employment or self-employment income for the entire four-week period.”

There may be other reasons related to COVID-19 beyond these examples why you may have stopped working.  However, you cannot voluntarily quit your job.

If you are concerned about the safety of your working conditions, you should discuss the situation with your employer.

Am I eligible to apply for the Canada Emergency Response Benefit if I have not declared that I earned any money in the last year?

While having filed income tax for 2019 is not an eligibility requirement, you will need to confirm when applying for the Canada Emergency Response Benefit that you had at least $5000 in employment or self-employment income in 2019 or in the 12 months prior to the date of your application.  You will also need to confirm that you have not earned more than $1000 in employment and/or self-employment income in a period of at least 14 consecutive days within the first benefit period and for the entire four-week benefit period of any subsequent claim. If you are deemed ineligible for the Benefit at a later date, you will be required to pay it back.

The income of at least $5,000 may be from employment and/or self-employment.  For those who are not eligible for Employment Insurance you may also include maternity and parental benefits under the Employment Insurance program and/or similar benefits paid in Quebec under the Quebec Parental Insurance Plan as part of the calculation for income.

Once I receive my first payment, can I assume I will receive my next payment 4 weeks later?

No, the renewal of payments will not be automatic. You must confirm your eligibility for each period for which you apply either online or by phone (1-833-966-2099).

If you are receiving your Benefit through Service Canada you must complete your Employment Insurance Report Card to confirm your eligibility.

The calculation of the 16 weeks begins with the first week for which you are receiving the Benefit.   However, the 16 weeks do not have to be taken consecutively.  For example, you could receive the Benefit for 4 weeks beginning March 15th and reapply for your second benefit period a few months later based on your personal situation.

April 22, 2020 Update on Student Support

$9 billion of funding in total for students have been anounced. They include:

  • Canada Emergency Student Benefit

    • $1,250/month from May to August

    • up to $1,750/month if you take care of someone else or have a disability

    • must be a post secondary student, going to school in September, or graduated in 2019

    • available if earning up to $1,000/month

    • apply through CRA

  • Canada Student Service Grant – those volunteering instead of working will be eligible for $1,000 to $5,000 based on the work done.

  • 76,000 student jobs will be created. Funds will be extended scholarship, fellowships and grants.

  • Student grants will be doubled for the 2020-2021 school year. Additional funding will be made available for Inuit, Metis and First Nations students.

Previously announced student measures include:

Canada Summer Jobs

  • The Canada Summer Jobs program provides opportunities for youth to develop and improve their skills within the not-for-profit, small business, and public sectors, and supports the delivery of key community services.

    We are making temporary changes to the Canada Summer Jobs program to allow employers to:

    • receive an increased wage subsidy, so that private and public sector employers can also receive up to 100 per cent of the provincial or territorial minimum hourly wage for each employee;

    • extend the end date for employment to February 28, 2021;

    • adapt their projects and job activities;

    • hire staff on a part-time basis.

Studen loans

  • All student loan borrowers will automatically have their loan repayments and interest suspended until September 30, 2020.

  • Students do not need to apply for the repayment pause.

  • This moratorium applies to the federal portion of student loans. Borrowers should check with their provincial or territorial student loan provider to see if payment is required on the provincial or territorial portion.

April 21, 2020 Update on 75% CEWS

  • 75% Canada Emergency Wage Subsidy

    • Registration will commence on April 27, 2020 and be first processed on May 4 in bulk.

    • Payments are targeted to begin on May 5.

    • 3,000 auditors have been assigned to manually review certain claims. They will review based on the size of the claims, or the size of employers. For example, 100% of claims made by large employers are expected to be reviewed. Most will be automatically processed. Reviews are intended to be completed in 72 hours.

    • 2,000 agents will be assigned to answer questions on the program.

    • A revised CEWS website and new calculator is available here.

  • $350 Million committed to an emergency community support fund

April 11, 2020 Update

On April 11, 2020, legislation (Bill C-14) was tabled to enact the 75% Canada Emergency Wage Subsidy.  The subsidy is available to eligible employers based on their eligible remuneration paid during certain 4-week periods.  Eligibility is based on sufficient declines in qualifying revenue.  The following are some of the key points, clarifications, and confirmations from today’s releases and legislation.

Eligible Remuneration

This includes wages, salaries or other remuneration.  Also, fees, commissions, or other amounts for services paid to “eligible employees” are included.  However, the subsidy is limited to the employee’s baseline remuneration (see below).

Baseline Remuneration

Baseline remuneration means the average weekly eligible remuneration paid to the eligible employee by the eligible entity during the period that begins on January 1, 2020 and ends on March 15, 2020, excluding any period of seven or more consecutive days for which the employee was not remunerated.

Remuneration Non-arm’s Length Employees

For these individuals, no more than 75% of baseline remuneration can be available as a subsidy.  In other words, if no remuneration was paid in January through March 15, 2020 to the individuals, no subsidy would be available.

Qualifying Revenue

This is the standard used to measure whether a sufficient decrease has occurred (15% for March, 30% for April).  It means the inflow of cash, receivables or other consideration arising in the course of the ordinary activities of the eligible entity.  It excludes extraordinary items and amounts derived from persons or partnerships not dealing at arm’s length with the employer.

  • Corporate Groups – Special rules for the computation of revenue take into account issues related to corporate groups. Affiliated groups would be able to compute revenue on a consolidated basis at their discretion. Certain entities receiving substantially all of their revenue from non-arm’s length sources will be permitted to determine their decline in revenue based on the decline in the non-arm’s length parties’ revenues. See Subsection 125.7(4).
  • Cash vs. Accrual – As previously announced, employers may choose to computer their revenue on the accrual or cash basis.  The legislation clarifies that “cash basis” will be computed as defined in Subsection 28(1), the provision commonly used for farming and fishing income.
  • Business with Cyclical Revenues – Minister Morneau verbally stated that as of now, he is satisfied with the current solution.

Future Eligibility

Once an employer meets the criteria in respect of a revenue decline, they would automatically meet the revenue decline criteria for the next period of the program.  For example, an employer with a revenue drop of more than 15% in March would qualify for the first and second periods of the program, covering remuneration paid between March 15 and May 9.

Qualifying Period

While government announcements indicate that the program is only available for 3 months (to June 6, 2020), the legislation allows flexibility for it to be extended to the end of September, 2020.


Employer’s premiums for employees that are on leave (not working) with pay are fully (100%) included in the subsidy.

Interaction with the 10% Wage Subsidy

Amounts enjoyed under the 10% subsidy will reduce the amounts eligible under the 75% subsidy.

Interaction with Work-sharing EI Benefit

The 75% subsidy is reduced for EI amounts received by the employees under the Work-sharing benefit.

Interaction with CERB and 75% Wage Subsidy

No subsidy is available for an individual who is without remuneration by the eligible entity in respect of 14 or more consecutive days in the qualifying period.  The Department of Finance backgrounder (updated April 11, 2020) noted that the Government will consider implementing an approach to limit duplication.  This could include a process to allow individuals rehired by their employer during the same eligibility period to cancel their CERB claim and repay that amount.  This would have to implemented in the future.


  • Multiple Employers in a Group – The maximum subsidy that may be claimed in respect of an individual that is employed by multiple non-arm’s length employers, is limited to a claim that would be made as if they had one employer.
  • Manipulation of Remuneration or Revenue – There are anti-avoidance rules that prevent artificial increases in remuneration eligible for the subsidy.  In addition, several rules have been proposed to target revenue manipulation that would entitle employers to the subsidy.


Minister Morneau reiterated his belief that the vast majority of Canadian businesses are honest, and will properly use the subsidy to enable them to maintain their workforce through the COVID-19 crisis.  He also reiterated that severe penalties will apply to the few who may seek to abuse the program.   This includes a new 25% penalty for employers manipulating their revenues, as well as existing penalty of 50% of an excessive claim for false statements or gross negligence, or as much as a 200% fine and five years’ imprisonment for fraud/tax evasion.

Information to Be Communicated

The Minister may communicate or otherwise make available to the public, in any manner that the Minister considers appropriate, the name of any person or partnership that makes an application under the 75% wage subsidy.

Payment Timing

Minister Morneau verbally stated that he expects money under the subsidy will be available within 2-4 weeks.

April 1, 2020 Update from the PM on Wage Subsidy and Emergency Response Benefit

As you’re probably aware, information on this is changing rapidly. However, at this time there is updated information to start applying for the CERB next week when application opens on Monday, April 6! Ensure you click on the links below for specific additional information from the Government of Canada and CRA on where to go to apply as well as additional eligibility criteria. For now, please note the following key highlights:

Canada Emergency Response Benefit (CERB):

  • Applications start on April 6 through CRA’s My Account.
  • If already applied for EI, no need to reapply for CERB.
  • Can’t get both the wage subsidy (see below) and the CERB.
  • Payment should be received within 3-5 days, if registered for direct deposit. CERB provides a payment of $2,000 for a 4-week period (equivalent to $500 a week) for up to 16 weeks. The income is taxable and there will be no source deductions. It is taxable when you file your 2020 income tax return.
  • Recipients are to confirm once a month that they are still out of work. This program is available from Mar 15 to Oct 3, 2020.
  • You must be residing in Canada (don’t need to be a citizen or permanent resident) and at least 15 years old.
  • You must have stopped work because of COVID-19 or otherwise, eligible for EI regular or sickness benefits
  • You must have had income of at least $5,000 in 2019 or in the 12 months prior to the date of your application. Income may be from any or a combination of the following sources: employment; self-employment; maternity or parental benefits.
  • You are or expect to be without employment or self-employment income for at least 14 consecutive days in the initial four-week period. In other words, if you’re currently receiving any type of income, you cannot apply. For self-employed individuals, you cannot have or expect to have any income for at least 14 consecutive days.
  • You are not eligible if you have not stopped working because of COVID-19. Also, if you voluntarily stopped work, you are also not eligible, you must have been forced to stop work as a result of COVID-19 to be eligible.
  • If you have already applied for EI, no need to apply for CERB.
  • To minimize disruptions and ensure the system is available for all to apply, the government have set up specific days for you to apply based on your birth month. E.g. if you’re born in Jan, Feb or Mar, you can apply on Monday, Apr 6. If you’re born in Apr, May or Jun, you can apply on Tuesday, Apr 7. See links below for details.
  • If you don’t already have My CRA Account set up with direct deposit, do so now. Otherwise, it will take more than 5 days to get your benefit. You can register to set up your account using the CRA link below.

New! General Info webpage and FAQ –

CRA Webpage to Apply for CERB:

Wage Subsidy:

  • The 75% subsidy will be available to non-publicly funded companies, charities, and not for profits. This program runs from March 15 to June 15, 2020
  • Entities must have a 30% decline in revenue since this time last year.  This is determined by comparing revenues to the same month last year for March, April or May. As a result, it is important to ensure you have adequate accounting records to determine your monthly revenue numbers.
  • Employers must reapply each month.
  • Employers must attest that they are doing everything that they can to pay the remaining 25%.
  • Applications may be made online on a CRA portal to be launched soon. If you’re not registered for direct deposit, this is the time to do so.
  • Funds will be available in approximately 6 weeks.
  • Stiff and severe penalties for those that take advantage of the system.
  • Employers are encouraged to rehire recently laid-off employees.
  • The 75% Wage Subsidy does not replace the earlier 10% Wage Subsidy that was announced earlier. However, you cannot get both. Since it is easier to qualify for the 10% Wage Subsidy program, we encourage you to first determine if you qualify for the 75% Wage Subsidy program. If not, then you can apply for the 10% Wage Subsidy program


We understand that many of you are bombarded daily with COVID-19 related information that may be overwhelming to navigate and digest. Recently, the Government of Canada released some details on their economic response to help families and businesses. We’ve been getting a lot of questions regarding this as many people are confused and don’t know what to do or how to start accessing these new programs. To help simplify the confusing information and provide some clarity, we hosted a webinar on Monday, March 30th at noon. You can watch a replay of this webinar using the link below:

Watch the March 30th Webinar Replay

Spots are limited so we encourage you to register early. Feel free to share with others, particularly business owners you may know.

Summary of Government’s COVID-19 Economic Response Plan

More Information on COVID-19

We encourage all our members and the chess community to remain safe and take proactive steps to protect themselves. In this respect, we continue to provide the following additional information:

What are the symptoms of COVID-19?

  • fever

  • cough

  • difficulty breathing

For the most up to date information on travel regarding COVID-19 please visit the Coronavirus disease (COVID-19): Travel Advice webpage on the government of Canada website.

As you may already know, many of the corona virus symptoms are similar to seasonal influenza. Should you experience these symptoms AND have recently traveled internationally to an affected region, we advise that you stay home and avoid contact with others and follow-up with your health care professional. Advise your health professional in advance of attending the clinic of your symptoms and travel history.

To help protect yourself from possible infection, health officials recommend that everyone:

  • wash your hands frequently and well with soap and warm water;

  • use alcohol-based hand sanitizer;

  • avoid touching your eyes, nose or mouth;

  • cough or sneeze into your elbow, or cover your cough or sneeze;

  • avoid close contact with anyone showing symptoms of respiratory illness;

  • stay home if you are sick and avoid contact with others;

  • if you are sick, contact a health care provider about your symptoms and inform them of your travel history.

Update on Mortgage Deferrals

Why Social Distancing and Strong Measures Are Critical

Social Distancing vs. COVID-19 (really simple visual article):

Stay up to date with COVID-19 Stats Analysis:

Other Useful Resources

Update on Mortgage Deferrals

Strategies for Handling Rent During COVID-19

COVID Workplace FAQs for Employers